On July 3, 2026, Ukraine submitted TBT notification G/TBT/N/UKR/392 to the WTO. The Ministry of Health of Ukraine launched a public consultation on the draft Resolution “On Amendments to Cabinet of Ministers Resolution No. 65 dated 20 January 2021” (the Technical Regulation on Cosmetic Products). Stakeholders may submit comments until 1 September 2026, which is 60 calendar days following the notification date.
The draft contains two core changes: first, extending the transitional period of the cosmetic Technical Regulation from August 3, 2026 to July 31, 2027; and second, clarifying the educational qualification requirements for the cosmetic safety assessor. CIRS Group has compiled the core contents of the draft for your reference.
Background
Ukraine's core cosmetic regulation is the Technical Regulation on Cosmetic Products, approved by Cabinet Resolution No. 65 of January 20, 2021, which is structurally aligned with the EU Cosmetics Regulation (EC) No 1223/2009 and requires cosmetics to complete electronic notification, undergo safety assessment, establish a Product Information File (PIF) and safety report, and have a Responsible Person / domestic agent fulfill the relevant obligations before being placed on the market. Ukraine had previously adopted Resolution No. 737 (G/TBT/N/UKR/351/Rev.1/Add.1) introducing a tiered transitional arrangement. The current draft further amends Resolution No. 65.
Main Contents of the Draft
1. Extension of the Transitional Period (to July 31, 2027)
The draft proposes to extend — from August 3, 2026 to July 31, 2027 — the transitional period during which cosmetic products placed on the market before the Technical Regulation entered into force, but which do not meet its requirements, may continue to be made available on the market. During this period, such products may not be prohibited or restricted from being supplied on the Ukrainian market solely on the grounds of non-compliance with the Technical Regulation.
2. Clarification of the Educational Qualifications of the Cosmetic Safety Assessor
The cosmetic safety assessment carried out in accordance with Part B of Annex 1 to the Technical Regulation on Cosmetic Products must be conducted by an expert (safety assessor) holding a Master's degree in the specialty “I2 Medicine” or “I8 Pharmacy” (or a related specialty included in the list of specialties approved by the Ministry of Health of Ukraine).
CIRS Reminder
The draft makes adjustments on both the transitional period and safety-assessor qualifications, with positive implications for cosmetics companies operating in or exporting to Ukraine. CIRS Group offers the following reminders:
- Make use of the extended transitional period: the original August 3, 2026 compliance milestone is postponed to July 31, 2027 — companies may back-plan formulation adjustments, label updates, and re-launch schedules accordingly, easing short-term compliance pressure;
- Confirm safety-assessor qualifications: cosmetic safety assessments in Ukraine must be conducted by an assessor holding a relevant Master's degree in medicine or pharmacy; pay attention to the alignment with the EU cosmetic Safety Assessor mechanism;
- Coordinate with Resolution No. 737: this amendment is linked to the already-effective Resolution No. 737 (tiered transitional periods) — companies should verify which transitional situation their products fall under to avoid misjudging the deadline;
- Participate in the consultation: relevant companies may submit comments on the draft to the Ukrainian Ministry of Health by September 1, 2026;
- Refer to the official text: the draft is still at the consultation stage; the final provisions and entry-into-force date are subject to the official resolution published by Ukraine.
If you need any assistance or have any questions, please get in touch with us via service@cirs-group.com.
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